Comment letters

Mazars USA LLP is committed to supporting professional standards and we are pleased to present our Comment Letters and responses related to recent, proposed accounting, auditing, professional standards, and regulatory changes. Our Comment Letters are prepared by our Quality & Risk Management team.

Learn more about Quality & Risk Management at Mazars here. 

Featured comment letters

PCAOB 

Re: PCAOB Release No. 2023-007 – Proposed Amendments to PCAOB Rule 3502 Governing Contributory Liability
November 3, 2023
Mazars USA LLP (“Mazars USA”) welcomes the opportunity to comment on the Public Company Accounting Oversight Board’s (“PCAOB” or the “Board”) proposed amendments in Release 2023-007 (the “Release”) to PCAOB Rule 3502 Governing Contributory Liability; PCAOB Rulemaking Docket Matter No. 053.

Re: PCAOB Release No. 2023-004 – Proposed Amendments Related to Aspects of Designing and Performing Audit Procedures that Involve Technology-Assisted Analysis of Information in Electronic Form
August 28, 2023
Mazars USA LLP (“Mazars USA”) welcomes the opportunity to comment on the Public Company Accounting Oversight Board’s (“PCAOB” or the “Board”) proposed amendments in Release 2023-004 (this “Release”) to PCAOB Auditing Standards related to aspects of designing and performing audit procedures that involve technology-assisted analysis of information in electronic form.

Re: PCAOB Release No. 2023-003 – Proposing Release: Amendments to PCAOB Auditing Standards related to a Company’s Noncompliance with Laws and Regulations And Other Related Amendments; PCAOB Rulemaking Docket Matter No. 051
August 7, 2023
Mazars USA LLP (“Mazars USA”) welcomes the opportunity to comment on the Public Company Accounting Oversight Board’s (PCAOB or the Board) proposed “Amendments to PCAOB Auditing Standards related to a Company’s Noncompliance with Laws and Regulations And Other Related Amendments” (the “proposed standards” or “proposed amendments”). Mazars USA appreciates the PCAOB’s work to enhance the quality of audit engagements through the revision of existing PCAOB audit standards.

Re: PCAOB Release No. 2023-001 – Proposed Auditing Standard – General Responsibilities of the Auditor in Conducting an Audit and Proposed Amendments to PCAOB Standards; PCAOB Rulemaking Docket Matter No. 049
May 30, 2023 
Mazars USA LLP (“Mazars USA”) welcomes the opportunity to comment on the Public Company Accounting Oversight Board’s (PCAOB or the Board) proposed audit standard regarding the auditor’s general responsibilities and related proposed amendments (collectively “proposed standard”) and related amendments. Mazars USA appreciates the PCAOB’s work to enhance the quality of audit engagements through the revision of existing PCAOB audit standards.

RE: PCAOB Release No. 2022-006 - A Firm's System of Quality Control and Other Proposed Amendments to PCAOB Standards, Rules, and Forms; PCAOB Rulemaking Docket Matter No. 046
February 1, 2023
Mazars USA LLP (“Mazars USA”) welcomes the opportunity to comment on the Public Company Accounting Oversight Board’s (PCAOB or the Board) proposed Quality Control standard (proposed standard or QC 1000) and related amendments. Mazars USA appreciates the PCAOB’s work to enhance the quality of audit engagements through the revision of existing PCAOB quality standards.

Re: PCAOB’s Proposed Amendments Relating to the Supervision of Audits Involving Other Auditors and  Proposed Auditing Standard – Dividing Responsibility for the Audit with Another Accounting Firm
November 30, 2021
Mazars USA LLP (“Mazars”) welcomes the opportunity to comment on PCAOB Release No. 2021-005 Rulemaking Docket Matter No. 042 Second Supplemental Request for Comment: Proposed Amendments Relating to the Supervision of Audits Involving Other Auditors and Proposed Auditing Standard – Dividing Responsibility for the Audit with Another Accounting Firm (the “proposed standard”). Mazars appreciates the PCAOB’s work to enhance the quality of audit engagements through the revision of the existing PCAOB standards.

Re: Interim Analysis No. 2020-01, Critical Audit Matter Requirements
June 15, 2020
Mazars USA LLP (Mazars) welcomes the opportunity to provide feedback on our initial experiences with Critical Audit Matters (CAMs), from the first stage of adoption of AS 3101, The Auditors Report on an Audit of Financial Statements When the Auditor Express an unqualified Opinion. Mazars appreciates the PCAOB’s efforts to gain an understand of our experiences, by performing an interim analysis before the second phase of CAM implementation begins.

FASB

RE: Proposed Accounting Standards Update, Income Statement—Reporting Comprehensive Income—Expense Disaggregation Disclosures (Subtopic 220-40): Disaggregation of Income Statement Expenses
October 30, 2023
Mazars USA LLP (Mazars USA) welcomes the opportunity to comment on the Proposed Accounting Standards Update, Income Statement—Reporting Comprehensive Income—Expense Disaggregation Disclosures (Subtopic 220-40): Disaggregation of Income Statement Expenses (proposed Update), issued by the Financial Accounting Standards Board (FASB).

RE: Proposed Accounting Standards Update, Compensation - Stock Compensation (Topic 718): Scope Application of Profits Interest Awards
July 7, 2023
Mazars USA LLP (Mazars USA) welcomes the opportunity to comment on the Proposed Accounting Standards Update, Compensation - Stock Compensation (Topic 718): Scope Application of Profits Interest Awards (proposed Update), issued by the Financial Accounting Standards Board (FASB).  

RE: Proposed Accounting Standards Update, Intangibles – Goodwill and Other – Crypto Assets (Subtopic 350-60): Accounting for and Disclosure of Crypto Assets
June 6, 2023
Mazars USA LLP (Mazars USA) welcomes the opportunity to comment on the Proposed Accounting Standards Update, Intangibles – Goodwill and Other – Crypto Assets (Subtopic 350-60): Accounting for and Disclosure of Crypto Assets (proposed ASU), issued by the Financial Accounting Standards Board (FASB).

RE: Proposed Accounting Standards Update, Income Taxes (Topic 740): Improvements to Income Tax Disclosures
May 30, 2023
Mazars USA LLP (Mazars USA) welcomes the opportunity to comment on the Proposed Accounting Standards Update (Update), Income Taxes (Topic 740): Improvements to Income Tax Disclosures, issued by Financial Accounting Standards Board (FASB).

RE: Proposed Accounting Standards Update, Leases (Topic 842): Common Control Arrangements (File Reference
No. 2022-ED500)
January 16, 2023
Mazars USA LLP (Mazars USA) welcomes the opportunity to comment on the Proposed Accounting Standards Update, Leases (Topic 842): Common Control Arrangements, issued by Financial Accounting Standards Board (FASB).

Re: Proposed Rule “The Enhancement and Standardization of Climate-Related Disclosures for Investors” - File Number S7-10-22
June 17, 2022
Mazars USA LLP, as the independent member firm of Mazars Group in the United States of America (“Mazars in US”) welcomes the opportunity to comment on the Proposed Rule The Enhancement and Standardization of Climate-Related Disclosures for Investors (“Proposed Rule”). . Mazars USA appreciates the PCAOB’s work to enhance the quality of audit engagements through the revision of existing PCAOB quality standards.

AICPA

Re: Proposed Statement on Auditing Standards –Special Considerations – Audits of Group Financial Statements (Including the Work of Component Auditors and Audits of Referred-To Auditors)
June 20, 2022
Mazars USA LLP (“Mazars”) welcomes the opportunity to comment on Proposed Statement on Auditing Standards –Special Considerations – Audits of Group Financial Statements (Including the Work of Component Auditors and Audits of Referred-To Auditors) (herein referred to as the “proposed standard” or “proposed SAS”). Mazars appreciates the AICPA’s work to enhance the quality of audit engagements through the revision of existing auditing standards.

Re: Proposed Statement on Accounting and Review Services – Quality Management for an Engagement Performed in Accordance with Statements on Standards for Accounting and Review Services
January 31, 2022
Mazars USA LLP (“Mazars”) welcomes the opportunity to comment on the Proposed Statement on Accounting and Review Services – Quality Management for an Engagement Performed in Accordance with Statements on Standards for Accounting and Review Services.

Re: Proposed Quality Management Standards (three interrelated standards) designed to Enhance and Maintain a CPA Firm’s Audit Quality
August 30, 2021
Mazars USA LLP (Mazars USA) welcomes the opportunity to comment on the questions raised by the
AICPA’s Auditing Standards Board (ASB) in their Exposure Draft on the proposed Quality Management
Standards (Proposed Quality Standards) 

Re: Proposed Statement on Auditing Standards – Inquiries of the Predecessor Auditor Regarding Fraud and Noncompliance with Laws and Regulations
June 30, 2021
Mazars USA LLP (“Mazars”) welcomes the opportunity to comment on Proposed Statement on Auditing Standards – Inquiries of the Predecessor Auditor Regarding Fraud and Noncompliance with Laws and Regulations.

Other

Re: Discussion Paper, Fraud and Going Concern in an Audit of Financial Statements: Exploring the Differences 
Between Public Perceptions About the Role of the Auditor and the Auditor’s Responsibilities in a Financial
Statement Audit)
February 1, 2021
Mazars USA LLP (Mazars USA) welcomes the opportunity to provide our insights on the questions raised in the International Auditing and Assurance Standards Board’s (IAASB or the Board) Discussion Paper, Fraud and Going Concern in an Audit of Financial Statements: Exploring the Differences Between Public Perceptions About the Role of the Auditor and the Auditor’s Responsibilities in a Financial Statement Audit (the Discussion Paper).

Re: Exposure Draft: Proposed International Standard on Auditing 600 (Revised), Special Considerations—Audits of Group Financial Statements (including the Work of Components Auditors)
October 2, 2020
Mazars USA LLP (Mazars USA) welcomes the opportunity to comment on the International Auditing and Assurance Standards Board’s (IAASB or the Board) Exposure Draft, International Standard on Auditing 600 (Revised), Special Considerations—Audits of Group Financial Statements (including the Work of Components Auditors) (ED-600 or the Exposure Draft).

Comment Letter – Request for Comment on the International Auditing and Assurance Standards Board’s (IAASB or the Board) Quality Management exposure drafts
July 1, 2019
Mazars USA LLP (Mazars USA) welcomes the opportunity to comment on the International Auditing and Assurance Standards Board’s (IAASB or the Board) Quality Management exposure drafts: Proposed International Standard on Quality Management 1, Quality Management for Firms that Perform Audits or Reviews of Financial Statements, or Other Assurance or Related Services Engagements (ED-ISQM 1), Proposed International Standard on Quality Management 2, Engagement Quality Reviews (ED-ISQM 2), and Proposed International Standard on Auditing 220 (Revised), Quality Management for an Audit of Financial Statements (ED-220) (collectively, the Proposed Standards).